Transfer Pricing

Our transfer pricing team offers Israel’s most comprehensive guidance on international transfer pricing, helping our clients to avoid costly audit, disputes and penalties. The team’s outstanding command of both Israeli and global requirements has resulted in an unmatched acceptance rate of their transfer pricing reports by both Israeli and worldwide tax authorities. Herzog Fox & Neeman is the only law firm in Israel that provides full transfer pricing services; the fact that under Israeli law our clients' matters are privileged and confidential, serves as an additional advantage of planning your international structure together with us.

Matching the continuously growing globalisation of Israeli companies and the increasing amount of foreign companies setting activities in Israel, our transfer pricing practice provides coherent transfer pricing solutions, responsive to the rapidly-changing markets in which multinational enterprises ("MNE") operate. Our transfer pricing team is experienced in complex and sophisticated matters of international tax and transfer pricing, and assists our clients in establishing their operations in Israel and abroad, as well as in documenting and protecting their intercompany transactions. When needed, our team also represents our clients in front of the tax authorities and in court.

Our practice is experienced with APAs and MAPs, and provides the full range of services to its clients, focusing on the legal, economic, and business related aspects of the client's tax structure and supply chain, employing innovative solutions. We represent our clients in both inbound and outbound transactions, in restructuring, audits, and of course the preparation of the required documentation in accordance with the changing regulatory environment, including the implementation of FAR, DEMPE and Value Chain Analysis. Each Master File, Local File, intercompany agreement and transfer pricing study we conduct, is given the full attention of the practice leader, attorney and economist Eyal Bar-Zvi.

Eyal often participates in discussions with and consults the Israeli Tax Authorities on transfer pricing circulars and the adequate interpretation and implementation of the OECD and other international transfer pricing regulations, shaping the future of transfer pricing regulations in Israel. Eyal serves as an adjunct professor and frequently lectures to the Israeli CPA Association on transfer pricing related matters.

Our services include:

  • Transfer pricing planning
  • Master File, Local File, and transfer pricing studies
  • Intercompany agreements
  • Transfer pricing policies (SOP)
  • Advance pricing agreements (APA)
  • Mutual agreement procedures (MAP)
  • Transfer pricing implementation
  • Intercompany finance
  • DEMPE and profit split analyses
  • Transfer pricing M&A Due Diligence

Transfer Pricing News & Insights

Meir Linzen


Corporate Tax, Employee Tax Benefits, Gaming, Indirect Taxes, Customs & International Trade, International Tax Planning, Internet & E-commerce, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax, Tax Controversy – Disputes & Litigation, Transfer Pricing, Value Added Tax (VAT)

Eyal Bar-Zvi


Commercial, Hi Tech, International Tax Planning, Mergers & Acquisitions, Tax, Transfer Pricing

Ari Siff

Transfer Pricing

Rotem Sheridan

Tax, Transfer Pricing

Yossi Shebson

Transfer Pricing

Nor Abo Ful


Tax, Transfer Pricing

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